AirClass Privacy Statement

This Privacy Statement is subject to change without notice.It was last updated and made effective on September 15, 2016

Stoneware, Inc. (“Stoneware”) recognizes that privacy and security are important for our customers and users of our products and services. This privacy statement describes how the AirClass service collects, uses and safeguards information provided through AirClass. Please also be sure to review the AirClass Terms of Service www.airclass.com/terms-of-service

AirClass is an instructor-led, online service specifically built for instructors, trainers, teachers and students. AirClass extends the classroom by enabling the user to instruct and engage with all students, even those who are not physically present over the web. By using AirClass, you consent to the collection and use of your information by Stoneware as described in the privacy statement currently in effect. Any changes to this privacy statement will be posted on our websites, so please check back periodically to ensure that you have the most current version.

WHAT INFORMATION IS COLLECTED AND HOW IS IT USED?

Stoneware may collect the following information through AirClass:

Personal Information, such as your name, e-mail addresses, contact information and related user profile data. We collect this information when you register for AirClass, create a user profile, complete a customer satisfaction survey, register for a marketing campaign or promotion and other points where the user chooses to provide such information.

Account log-in credentials, such as usernames and passwords, which authenticate users of AirClass.

Device identifiers and related information, such as device id, serial number, IMEI, MAC address, IP address and domain names. We use this information to measure the use of our sites; to improve the content of our sites; and to provide tailored advertisements. Aggregated information is not used in such a form that would enable direct connection of any personal information to our visitors

Certain data on our users' demographics, interests, and behavior based on the information provided to us when using AirClass, during a promotion, from surveys and from our server log files. We do this to better understand and serve our users and customers, as well as to determine how we can improve our products. This research is compiled and analyzed on an aggregated basis so as to prevent identification of personal information relating to any one individual. Stoneware may share this aggregated data with our agents (service providers).

In addition, AirClass Emotion Insights, powered by Applied Recognition, Inc. is a gesture analytics feature embedded within AirClass that collects and analyzes video of a student’s participation, including facial images and gestures, in a class or training session provided on AirClass. AirClass Emotion Insights gesture analysis assists instructors, trainers and teachers in assessing their effectiveness in delivering a lesson or educational content in a class or training session provided on AirClass. AirClass Emotion Insights’ gesture analysis of student video is summarized in anonymous and aggregated forms only and supplied only to the instructors, trainers and teachers of the class or training session provided on AirClass. Please see “Who is collecting and using the information?” below for additional context.

WHAT ABOUT INFORMATION COLLECTED FROM CHILDREN?

AirClass has been developed to be used in a range of diverse educational environments. This includes circumstances where a district, school, institution or instructor has chosen to make AirClass available as a resource for children under the age of 18 and, in certain cases, for children under the age of 13. Therefore, the personally-identifiable and non-personally identifiable information types described above may be collected from children.

Where children under the age of 18 are concerned, we require that the district, school, institution or instructor agree to the Airclass Terms of Service and this Privacy Statement. In addition, Stoneware requires that the district, school, institution, instructor and/or teacher comply with all requirements set forth under the Children’s Online Privacy Protection Act (COPPA) in the United States. In particular, Stoneware requires that the district, school, institution, instructor and/or teacher acquire parents’ or guardians’ written consent by signing the AirClass Parental Consent Form, available at www.airclass.com/privacy/permission-form prior to allowing children to use AirClass. The district, school, institution, instructor and/or teacher are responsible for keeping all signed AirClass Parental Consent Forms on file and making them available upon request. Additional information on COPPA is available at: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions.

If you are under the age of 18 and your parents or guardians have not provided written consent, please do not send any personal information about yourself through AirClass or through any other means to Stoneware. If a child under the age of 18 submits personal information to Stoneware without the written consent of parents or guardians, we delete the information as soon as we discover it was provided by a child under 18 years of age and do not use it for any purpose. Stoneware encourages parents to take an active role in their children's use of the Internet and mobile applications and to inform them of the potential dangers of providing information about themselves.

If you are under the age of 18, we also encourage you to review this Privacy Statement and the AirClass Terms of Service with your parents or guardians. Please also note that your parents or guardians, as well as your district, school, institution or instructor may be able to view information relating to your use of Stoneware including, but not necessarily limited to, your grades or scores, your messages created or submitted through AirClass or any other content generated through AirClass.

DOES AIRCLASS USE COOKIES AND RELATED TECHNIQUES?

In order to provide an effective, efficient and customized experience, AirClass may use Internet cookies, [Flash cookies], tags, web beacons, analytics (including Google Analytics) and related website solutions and techniques. These solutions are usually supplied to Stoneware by third parties.

Cookies store bits of information about your use of AirClass that help remind us who you are. They can save your password, preferences and other details so that your next session goes faster and so that you receive relevant information regarding AirClass and Stoneware.

The use of cookies is relatively standard. Most browsers are initially set up to accept cookies. However, if you prefer not to store cookies, you can choose to:

However, please note that certain Stoneware websites, applications and services may not respond to Do-Not-Track signals sent by certain browsers. You should also understand that some features of AirClass may not function properly if you don't accept cookies.

WHO IS COLLECTING AND USING THE INFORMATION?

When you use AirClass, you are sharing that information with Stoneware, its subsidiaries and affiliated companies for the purposes described above. Additionally, Stoneware contracts with other companies who act as our agents to perform services for Stoneware, such as data hosting, processing, product development and analytics. In such cases, we take steps to ensure that these suppliers to Stoneware are adhering to Stoneware’s standards for privacy and security. Stoneware does not sell or rent any AirClass user information.

Please note that, in special cases, we may need to share information without acquiring consent, such as when we believe in good faith that the law requires it, or to identify, contact or bring legal action against someone who may be violating the Airclass Terms of Service or may be violating Stoneware's or others’ rights or causing injury to or interference with Motorola's or others’ property.

The AirClass service may also contain various links to third-party websites or services that may provide additional information, services or promotions. These sites and services may be operated independently of Stoneware and have their own separate privacy and data collection practices. Any information you provide to these websites and services will be governed under the terms of their privacy policy, if any. Stoneware has no responsibility or liability for the actions or policies of these independent sites and services and is not responsible for the content or privacy practices of such sites.

AirClass Emotion Insights Gesture Analytics:

In addition, AirClass Emotion Insights, powered by Applied Recognition, Inc., is a gesture analytics feature embedded within AirClass that collects and analyzes video of student participation, including facial images and gestures, during a class or training session provided on AirClass. Review of gesture analytics from a student’s participation assists instructors, trainers and teachers in assessing their effectiveness in delivering a lesson or educational content via a class or training session provided on AirClass. Video of student participation, including facial images and gestures, is recorded using the camera on the student’s device and sent to an authorized Stoneware third party cloud service provider for digital processing. Processing takes approximately two-times the length of the video recorded (e.g., a 30 min video would take 60 minutes to process) and once analyzed, it is immediately deleted from the cloud application . AirClass Emotion Insights’ gesture analysis of student video is summarized in an anonymous and aggregated form only and supplied only instructors, trainers and teachers of the class or training session provided on AirClass.

HOW IS MY INFORMATION SECURED?

When you provide your information via AirClass, we use certain security measures, such as strong authentication techniques, access controls and encryption, where appropriate. Encryption scrambles the information so it can only be viewed by Stoneware. Stoneware uses Secure Socket Layer (SSL) encryption technology, where appropriate, for Internet-based transactions.

However, no data transmission over the Internet can be guaranteed to be completely invulnerable.As a result, while we have taken appropriate steps to protect your personal information, Stoneware cannot ensure or otherwise warrant the security of any information you provide to us and therefore you use AirClass at your own risk.

As a global company Stoneware has websites, applications and users all over the world. The information you provide may be transmitted, used, processed and stored outside of the country where you submitted that information, including countries that may not have data privacy laws that provide protection equivalent to such laws in your home country. Whenever Stoneware handles personal information, regardless of where this occurs, we take appropriate steps to ensure that your information is treated securely and in accordance with the relevant Terms of Service, this Privacy Statement and all applicable laws and regulations.

How can I access my personal information and where can I go with any questions?

You have the right to access (review, correct or delete) your personal information by contacting Stoneware or by managing your user profile in AirClass. Users of AirClass are responsible for providing Stoneware with accurate and complete personal information and for contacting Stoneware if correction of such information is required. Please note that we reserve the right to disallow unreasonable requests for access. If you have registered for marketing communications or subscription updates from Stoneware, please follow the “unsubscribe” or “opt-out” instructions in that communication.